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Letter from the Biometrics and Surveillance Camera Commissioner to the Security Minister




November 2, 2022

Dear Minister

Government Working Group on the Protection of Democratic Society

Allow me to offer you my sincere congratulations on your new role and to welcome the substantial addition it will, I believe, bring to some of the key areas of public space surveillance about which, as you know from ‘After the correspondence between our respective offices, I have worried since the start of my appointment last year.

State-controlled surveillance companies

The role of state-controlled surveillance companies whose products are now deeply embedded in almost every aspect of our lives, not only within our “competent authorities” for which I am responsible (police agencies and local authorities ), but through our critical national infrastructure most widely evidenced in the report released under your chairmanship by the House of Commons Foreign Affairs Committee on the appalling treatment of Uyghur Muslims in China’s Xinjiang Uyghur Autonomous Region. This report has provided an authoritative evidence base on which I have been able to engage with many stakeholders including Ministers, Chief Constables, Police and Crime Commissioners, local authorities, civil society groups, fellow lawyers and academics.

Subsequent events such as publicity on security camera footage from the then Secretary of State for Health and Social Care, as well as considerable international coverage of Chinese-owned surveillance capabilities in the UK highlighted the level of public interest and concern in this area.

While I was heartened by the sympathetic reception and empathetic feedback I received, and warmly welcome the legislative response such as the National Security and Investment Act 2021 and the proposed procurement law currently before Parliament, there is an urgent need for real momentum if we are to understand the magnitude of the risk presented by this proliferation of surveillance and the dependencies we have created on it.

In this regard, I was very interested to learn this week that you have set up a task force to address the risks to British democracy.

As a society, we are becoming accustomed to the surveillance of public space. Technological developments mean that our ability to prepare for, respond to and recover from global crises has increased beyond anything our ancestors could have realistically imagined. Every aspect of our critical national infrastructure, whether it is energy security, mass public transport, food and water supply or emergency services, depends to some degree on a capacity reliable and secure surveillance. When extended to courts, prisons, schools, places of worship, sports and entertainment venues, elections, public demonstrations and other areas of democratic activity, the sensitivities and risks of what has been called omniveilence[footnote 1] are amplified and we need to be able to trust the whole surveillance ecosystem, to be sure that what is technologically possible is only done in a way that is both legally permitted and socially acceptable.

Trusted Monitoring Partnership

As nearly all of our technological capacity is privately owned, the people we trust (police, emergency services, local and national government) must be able to trust their surveillance partners, otherwise we will have a lot of wrong, not just as an industry, but as a society. In this context, trust means a willingness to participate in a minimum level of public scrutiny, whether it is about your products and services or your business history, values ​​and principles. If, like some surveillance companies I currently deal with, entities are unwilling to accept this scrutiny and responsibility, it is a business decision for them, but it is a decision that I believe should prevent us from working in a trusted partnership with our democratic institutions.

In my view, if we are to get the most out of surveillance technology, we will need a systemic approach to regulation that focuses on the integrity – of technology and practice – as well as clear standards for everything and for everyone involved because, in a systemic framework, if you contaminate one part, you contaminate the whole. Biometric surveillance capability in its broadest sense could revolutionize our public services: at the same time, the way this technology is used could jeopardize our very model of policing, local and national government and the societal values ​​upon which it is based. is founded.

People need to be able to trust the relevant surveillance technology that does what it’s supposed to do, but that means the whole ecosystem that uses surveillance cameras and biometrics, not just new offshoots of it. More concretely, it also means having the same confidence that the operators of these systems and tools do what they are supposed to do; it means understanding the purposes for which the technology is being used, who authorized it and how they came to their decision that it was legal and proportionate to do so in each case. And it means having clearly defined, published, accessible and intelligible policies, publicly setting the parameters, policies that will be regularly reviewed in the light of experience.

In this context, I believe that the role of surveillance of public space and those who provide it has itself become part of our critical national infrastructure and I would encourage your task force to take this into account from the outset. .

I look forward to our next meeting on November 14 and to working with you to meet these challenges.


Professor Fraser Sampson

Commissioner for biometrics and surveillance cameras